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Switzerland - IRAS

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(i)<br />

(ii)<br />

on income (total income, earned income, income from capital,<br />

industrial and commercial profits, capital gains and other items of<br />

income); and<br />

on capital (total property, movable and immovable property, business<br />

assets, paid-up capital and reserves and other items of capital)<br />

(hereinafter referred to as "Swiss tax").<br />

4. The Convention shall also apply to any identical or substantially similar taxes which<br />

are subsequently imposed in addition to, or in place of, the existing taxes.<br />

5. The Convention shall not apply to Federal anticipatory tax withheld at the source on<br />

prizes in a lottery.<br />

6. If taxes on capital or on capital gains are introduced in Singapore at some future date<br />

the Convention shall apply to such taxes.<br />

Article 3<br />

1. In this Convention, unless the context otherwise requires:<br />

(a)<br />

(b)<br />

(c)<br />

(d)<br />

(e)<br />

(f)<br />

(g)<br />

(h)<br />

(i)<br />

the term "Singapore" means the Republic of Singapore;<br />

the term "<strong>Switzerland</strong>" means the Swiss Confederation;<br />

the terms "a Contracting State" and "the other Contracting State" mean<br />

Singapore or <strong>Switzerland</strong>, as the context requires;<br />

the term "tax" means Singapore tax or Swiss tax, as the context requires;<br />

the term "person" includes an individual, a company and any other body of<br />

persons, corporate or not corporate;<br />

the term "company" means any body corporate or any entity which is treated<br />

as a body corporate for tax purposes;<br />

the terms "enterprise of a Contracting State" and "enterprise of the other<br />

Contracting State" mean respectively an industrial, mining, commercial,<br />

timber, plantation or agricultural enterprise or undertaking carried on by a<br />

resident of a Contracting State and an industrial, mining, commercial, timber,<br />

plantation or agricultural enterprise or undertaking carried on by a resident of<br />

the other Contracting State;<br />

the term "international traffic" means any transport by a ship or aircraft<br />

operated by an enterprise of a Contracting State, except when the ship or<br />

aircraft is operated solely between places in the other Contracting State;<br />

the term "competent authority" means:<br />

(i)<br />

in the case of Singapore: the Minister for Finance or his authorised<br />

representative;<br />

26

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